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NY 880543

November 25, 1992

CLA-2-84:S:N:N1:110 880543


TARIFF NO.: 8471.99.1500

Mr. David I. Wilson
Arter & Hadden
1801 K Street, N.W., Suite 400K
Washington, D.C. 20006-1301

RE: The tariff classification of an "Iopro" asychronous multiport board and an "Iolan" computer terminal server from the United Kingdom

Dear Mr. Wilson:

In your letter dated November 12, 1992, on behalf of Chase Research, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves two models of LAN equipment that are used in a local area network for interconnecting terminals, printers, and modems.

The "Iopro" asynchronous multiport boards are installed inside of a personal computer and provide eight or more serial port connections for terminals, printers, and modems. Both the "Iopro" and the "Iolan" operate in the Unix environment and use the TCP/IP (telnet/rlogin) communications protocol to link together various types of ADP equipment into LANs. The "Iopro" is most often used with relatively simple computer systems such as those found in doctors' or dentists' offices and small law firms. The device consists of two components: 1. a stuffed printed circuit board with an 80C186 chip operating at 16 MHz, that fits into one of the expansion slots inside of a PC and 2. one or more port "pods" that are external to the PC. The "pods", which are physically joined together if there is more than one of them, connect to the PC by means of an eight-foot cable. The "Iopro" works by allowing a PC user to select options from a menu that appears on the screen of the PC monitor. The execution of the computer programs loaded into RAM enables the various forms of ADP equipment on the LAN to communicate with each other and thereby to process data according to users' commands.

The "Iolan" is a terminal concentrator subsystem that features eight or sixteen RS232C asynchronous serial ports, enabling terminals, printers, and modems to communicate over an Ethernet backbone with other nodes or one or more host computer system on the network. It incorporates a 16-bit 80C186 processor running at 16 MHz which manages all on-board processing tasks. This unit incorporates 1 Mb of RAM, and is most often used with complex computer systems such as those found in banks, corporate offices and large law firms. The "Iolan" uses electronic circuitry and firmware basically similar to those used by "Iopro", but in Iolan both the circuit board and ports are housed together in a box entirely external to a PC.

Noting Legal Note 5 (B) to Chapter 84 of HTS, and recent HQ ruling letter 952659 of October 7, 1992, these two devices appear to be principally used to effectuate interconnection of the CPU unit to other units or ADP machines, thereby serving "control" and "adaption" functions.

The applicable subheading for the "Iopro" and "Iolan" network units will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for control or adapter units. The rate of duty will be free.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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